"Whether and how the use and control of subcontractors would be affected by
allowing the third-party testing of component parts."
This is the hardest question for me, because I don't contract out, and have no experience with the manufacturing process outside my own basement. So here goes.
A quality control system would have to be put in place that may include randomizing testing and implementing stricter quality control processes. Instead of checking the first few from a production run, a manufacturer might pull and spot check somewhere down the production line. That way if the contractor has substituted a tested component for another, a check against the original components could be performed. In the apparel industry, this could be performed by a visual inspection compared against the original compliant components specified by the manufacturer.
As for toys, or other products, this might be harder to determine. Whether a certain paint has been swapped for another, might be difficult to tell without doing random unit testing. However, if you did do unit testing on one of the first few from the production run, and then later on a switch was made, unit testing wouldn’t have made that product any safer versus component testing. It really comes down to random quality control.
I welcome all of your comments to help me formulate these responses, as I'm pretty sure I'm not aware of many of the complicating factors that many businesses face.
_________________
Showing posts with label comments. Show all posts
Showing posts with label comments. Show all posts
Monday, December 29, 2008
Saturday, December 27, 2008
CPSIA Comments, Question 4
On to Question 4:
"Assuming all component parts are compliant, what manufacturing processes and/or environmental conditions might introduce factors that would increase the risk of allowing non-compliant consumer products into the marketplace."
There is no manufacturing process that has the possibility of introducing lead unless it involves introducing a new component that might contain lead, ie. solder. Simply heating, sewing, cutting, ironing, and the like, cannot change the chemical make up of the unit, and will not introduce lead if it doesn't already exist.
If however during the process of manufacturing, an untested component is introduced such as solder or a surface coating, then that might change whether or not the unit is compliant. But, the fact remains that if all the components have been tested, then processing those components will not alter the chemical compounds significantly enough to pose any hazard.
My husband and I laughed at this one this morning. Short of alchemy, or having a nuclear reactor in your manufacturing facility, introducing lead where none exists is impossible.
"Assuming all component parts are compliant, what manufacturing processes and/or environmental conditions might introduce factors that would increase the risk of allowing non-compliant consumer products into the marketplace."
There is no manufacturing process that has the possibility of introducing lead unless it involves introducing a new component that might contain lead, ie. solder. Simply heating, sewing, cutting, ironing, and the like, cannot change the chemical make up of the unit, and will not introduce lead if it doesn't already exist.
If however during the process of manufacturing, an untested component is introduced such as solder or a surface coating, then that might change whether or not the unit is compliant. But, the fact remains that if all the components have been tested, then processing those components will not alter the chemical compounds significantly enough to pose any hazard.
My husband and I laughed at this one this morning. Short of alchemy, or having a nuclear reactor in your manufacturing facility, introducing lead where none exists is impossible.
Friday, December 26, 2008
CPSIA Question 3
Forgive me if this is a tad incoherent, and replete with run-on sentences, but I wanted to get something down on paper before I headed to bed. Here is the next question that the CPSC is taking comments on regarding component testing.
The conditions, if any, under which supplier third-party testing of raw materials or components should be acceptable.
The conditions which supplier third-party testing of raw materials and components should be accepted is if the manufacturer using those raw materials does not alter them in any chemical way. For example, a fabric manufacturer tests each fabric for lead and it is under the allowable limit according to the CPSIA. The fabric manufacturer then sends a copy of the test results to the manufacturer of the children’s product, or has them available electronically. Provided the manufacturer of the children’s product does not chemically alter the fabric (painting, surface coating, etc.), then that supplier third party test should satisfy the requirement of the CPSIA. It would not be cost effective to retest already tested materials, and retesting would not make that particular product any safer for the child. If the manufacturer is cutting and sewing a raw material, and not altering it in any other way, supplier third party testing should be acceptable.
Moreover, the cost of testing already tested materials not only hinders business, but it is redundant and unnecessary. As manufacturers seek out raw materials that are inherently lead free, or have already been tested by the supplier and shown to comply in order to avoid costly testing, the likely result is that less lead will be introduced into the supply chain. The demand for supplies that have already been tested would likely rise. If a supplier cannot prove that his raw material complies with the law, then the demand for his product would go down, resulting in fewer raw materials that contain higher levels of lead.
In fact there are many European standards that already exceed regulations set forth in the CPSIA to date, and as such should be allowed as part of a testing program. Supplier provided certifications would dramatically lessen the economic impact on small businesses, and allow many to continue operations.
The conditions, if any, under which supplier third-party testing of raw materials or components should be acceptable.
The conditions which supplier third-party testing of raw materials and components should be accepted is if the manufacturer using those raw materials does not alter them in any chemical way. For example, a fabric manufacturer tests each fabric for lead and it is under the allowable limit according to the CPSIA. The fabric manufacturer then sends a copy of the test results to the manufacturer of the children’s product, or has them available electronically. Provided the manufacturer of the children’s product does not chemically alter the fabric (painting, surface coating, etc.), then that supplier third party test should satisfy the requirement of the CPSIA. It would not be cost effective to retest already tested materials, and retesting would not make that particular product any safer for the child. If the manufacturer is cutting and sewing a raw material, and not altering it in any other way, supplier third party testing should be acceptable.
Moreover, the cost of testing already tested materials not only hinders business, but it is redundant and unnecessary. As manufacturers seek out raw materials that are inherently lead free, or have already been tested by the supplier and shown to comply in order to avoid costly testing, the likely result is that less lead will be introduced into the supply chain. The demand for supplies that have already been tested would likely rise. If a supplier cannot prove that his raw material complies with the law, then the demand for his product would go down, resulting in fewer raw materials that contain higher levels of lead.
In fact there are many European standards that already exceed regulations set forth in the CPSIA to date, and as such should be allowed as part of a testing program. Supplier provided certifications would dramatically lessen the economic impact on small businesses, and allow many to continue operations.
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